Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
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